Code of Business Ethics

MetLife’s Code of Business Ethics helps us live our purpose with every customer every day. It helps us navigate an always-changing external environment while meeting the highest professional standards. We regularly update the Code to reflect prevailing norms, updates to internal policies and market conditions, among other issues. In 2022, MetLife published an updated Code to align with changes to internal policies related to speaking up, treating customers fairly, protecting the privacy rights of our customers and employees, and personal trading.

The Code is the foundation for our Success Principles and represents our core values for conducting business. Our Success Principles articulate the behaviors that MetLife employees are expected to exhibit, and those that help us deliver on our purpose and execute on our strategy. Our Code of Business Ethics is available in 18 languages and applies to all employees. Each year, employees pledge that they commit to and comply with the Code.

In the Code, we confirm our commitment to conducting business fairly, honestly and openly, and a zero-tolerance policy toward all forms of bribery and corruption that may be committed by MetLife employees or a third party acting for or on behalf of MetLife. We also maintain supplemental codes, including the Financial Management Code of Business Ethics and the Supplier Code of Business Ethics.

Code of Business Ethics training encourages employees to have an ownership mindset, speak up and escalate concerns when they arise. 98%¹ of employees completed the 2022 Code of Business Ethics training.

Raising Concerns and Speaking Up—Employees, Customers and Suppliers

We understand the importance of an environment in which employees feel empowered to speak up. We encourage employees to lead by example, holding themselves and others accountable by raising issues and concerns. Employees can speak up using the channel that is most comfortable for them and can report anonymously, were permissible by law.

Reporting channels include:

• Ethics & Fraud HelpLine, available globally;
• Speak Up Tool, a desktop icon available to all employees;
• Corporate Special Investigations Unit;
• Local or Regional Compliance Risk Management;
• Local or Regional Helpline or Whistleblowing Contact;
• Local or Regional HR or Employee Relations; and
• Direct supervisor, next-level supervisor and any other level of management.